Union of India v. Col. P.P. Singh
Quick Reply: File notings and the opinion of the Judge Advocate General are “information” under §2(f) of the RTI Act. The Delhi High Court dismissed the Union's writs and sustained the CIC orders directing supply.
High Court of Delhi · 9 November 2012 · WP(C) 1138/2012
A conjoint reading of Section 2(f) and 2(i) leaves no doubt that it is an expansive definition. There is an express reference to opinions and advices.
Case details
| Court | High Court of Delhi |
|---|---|
| Decided | 2012-11-09 |
| Citation | WP(C) 1138/2012, with WP(C) 499/2012 and WP(C) 1144/2012 |
| Bench | Rajiv Shakdher J |
| Petitioner | Union of India |
| Respondent | Col. P.P. Singh, with Col. V.K. Shad and Brig. S. Sabharwal in the companion writs |
| RTI Act sections | §2(f), §2(i), §8(1)(e), §8(1)(j), §10 |
| Outcome | Writ petitions dismissed. CIC orders sustained. Information to be supplied within two weeks. |
Holding
The common question was whether the Union was obliged to furnish file notings and the opinion of the Judge Advocate General under the RTI Act. The Court held that those records are information. The writ petitions were dismissed. The impugned CIC orders were sustained. The information sought was to be supplied within two weeks, in terms of the CIC orders, including redaction of names under §10(1) where the CIC had so directed.
Ratio
Section 2(f) defines information as any material in any form, including records, documents, opinions and advices. Section 2(i) defines record to include a file. “A conjoint reading of Section 2(f) and 2(i) leaves no doubt in my mind that it is an expansive definition even while it is inclusive which, brings within its ambit any material available in any form. There is an express reference to 'opinions' and 'advices'… there can be no doubt that file notings and opinions of the JAG branch are information.”
The Union's §8(1)(e) fiduciary argument, that officers in the chain of command hold opinions in trust, did not succeed as a blanket bar. Access remains subject to the exemptions that actually apply on the facts, and to severance under §10. This judgment is not a ruling on the cabinet-papers exemption in §8(1)(i).
Section(s) applied
- Section 2(f) - information includes opinions and advices
- Section 2(i) - record includes a file
- Section 8(1)(e) and Section 8(1)(j) - exemptions argued, not a standing bar on notings
- Section 10 - severance of names and designations as already directed by the CIC
Related
Sources
- Union Of India & Anr. vs Col. P.P. Singh on 9 November, 2012, High Court of Delhi, https://indiankanoon.org/doc/65728123/ - title line as indexed. Judgment delivered on 09.11.2012.
- RTI Act, 2005, s.2 as published on this site.
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Last reviewed: 11 September 2026.